Editor’s Note: Cross-posted from OIRA Watch.
It seems likely that the CFPB will follow the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) and convene a Review Panel as the next step in the debt collection rulemaking process. However, as of this date the CFPB has not made any formal announcements about the formation of a SBREFA panel for debt collection.
Under SBREFA, when developing rules that may have a significant economic impact on a substantial number of small businesses, the CFPB, in conjunction with the Small Business Administration (SBA) and the Office of Management and Budget (OMB), is required to form a Review Panel to obtain input from a group of small business representatives. The Panel is selected by the CFPB in consultation with the SBA.